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Home My WebLink About12-6201~ ~r IN THE ('OURT OF COMMON PLEAS, CUMBERLAND COUNTY, PF,NNSYL.VANIA PPL ELECTRIC UTILITIES CORPORATION, VS. BAMBI ,T vEVILLE, Civil Action - In La Plaintiff, No. 1~ l ~ a ~ ac~i ..1 Y"gal ARBITRATION ~ ~ "`_-, ~ ~; -~ --.+ -~ C.~"7 y a ~y s. ~ } ' `-" is °:: ~} ` Defendant. ~e~ ~' =~ ~~ r..~ ~ ~`j ~' COMPLAINT NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served by entering a written appearance, personally or by attorney, and filing, in writing, with the Court, your defenses or objections to the claims set forth against you. You are WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166 (800) 990-9108 S' a~t~~ 103. ~Spc~ a~ Lk,a ist7o 12a-a~~s~2- iN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA PPL ELECTRIC UTILITIES CORPORATION, Civil Action - In Law -_~ Plaintiff, No. ~ `~-- LpaO( ~~ vs. ARBITRATION BAMBI ,I. ~~iEVILLE, Defendant COMPLAINT l . This is an action by Plaintiff, PPL ELECTRIC UTILITIES CORPORATION to recover damages from Defendant arising out of a vehicular collision which caused damage to property owned by Plaintiff. ?. PPL ELECTRIC UTILITIES CORPORATION is a Pennsylvania corporation duly organized and existing and licensed to do business as a public utility under the laws of the Commonwealth of Pennsylvania with a principal place of business at Two North Ninth Street, Allentown. Pennsylvania, 18101. ~. Defendant, BAMBI J. NEVILLE, is an adult individual residing at 343 Main Street, East Greenville, Pennsylvania, 18041. ~. At all times relevant hereto, Plaintiff was engaged in the business of furnishing, supplying and distributing utility service to persons and businesses who requested utility service in accordance with the Rate Schedules and General Rules and Regulations of Plaintiffs Tariff presently on file with the Public Utility Commission. COUNTI PPL ELECTRIC UTILITIES CORPORATION VS. BAIVIBI J. NEVILLE 5 Defendant, BAMBI J. NEVILLE, while operating a vehicle, damaged property owned by Plaintiff. G Defendant negligently operated the vehicle in that he/she: a) operated said vehicle while under the influence of alcohol; h) operated said vehicle and/or equipment at an excessive rate of speed under the circumstances; c) failed to have said vehicle and/or equipment under proper and adequate control; d) failed to keep a proper lookout; e) operated said vehicle and/or equipment in a reckless and careless manner; f) failed to keep vehicle and/or equipment in the proper lane of travel; g) failed to operate the vehicle and/or equipment within the posted speed limit or failed to operate the vehicle and/or equipment at a reasonable speed under the circumstances; h) failed to remain alert and attentive under the circumstances: i) operated the vehicle and/or equipment without due regard for the rights, safety and position of the Plaintiff; j) operated the vehicle and/or equipment in a manner violating the statutes of the Commonwealth of~ Pennsylvania governing the operation of vehicles and/or equipment on public streets, highways and roadways; k) being negligent at the law; and 1) such other acts or omissions constituting carelessness, negligence and recklessness may be ascertained during discovery or developed at the time of trial. 7. Defendant, on or about October 8, 2010, struck and damaged overhead facilities owned and operated by PPL ELECTRIC UTILITIES CORPORATION in the vicinity of 1500 Main Streer, Mechanicsburg, Cumberland County, Pennsylvania. b. Defendant's actions or inaction as set forth above are the proximate cause of the damages a~ set for above and herein. 9 Plaintiff made demand on Defendant to repay the sums then due and owing to Plaintiff, but Defendant has refused to pay Plaintiff. 10 Plaintiff has been damaged in the amount of $14,697.50, including costs and attorneys fees. WHEREFORE, Plaintiff, PPL ELECTRIC UTILITIES CORPORATION, demands judgment against the Defendant in an amount of $14,697.50, including costs, pre judgment and post-judgment interest, punitive damages and delay damages as the law may allow. Respectfully submitted, DATED: October 2, 2012 By: KRZYWICHI & ASSOCIATES, P.C. (215) 862-4390 Attorney for Plaintiff Attorney LD. 2754 VERIFICATION Pursuant to Rule 1024 (c), I, Anthony P. Krzywicki, Esquire, verify that I am the attorney for Plaintiff, in the within case; that the appropriate officers of the plaintiff are not available within the time for serving the foregoing to provide their verification; that I am sufficiently familiar ~~irh the facts set forth in the foregoing Pleading to take this verification; and that such facts are true and correct to the best of my knowledge, information and belief, based upon the company's business records and matters of public record. I understand that the statements herein are made subject to the penalties of 18 Pa. Consol. Stat. Ann. ~ 4904 relating to unsworn fal siti cati on to authorities. DATED: Uetober 2, 2012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor PPL Electric Utilites {:orporation ,JS Case Number Bambi Jill Neville 2012-6201 SHERIFF'S RETURN OF SERVICE 10/08/2012 Ronny R Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Bambi Jill Neville, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint and Notice according to law. 10/12/2012 11:10 AM -York County Return: And now October 12, 2012 at 1110 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Bambi J. Neville by making known unto Raymond Skoloda, Father of Bambi .J. Neville at 728 Old Quaker Road, Apartment 8, Lewisberry, Pennsylvania 17339 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 2~. 2012 SO ANSWERS, RONN R ANDERSON. SHERIFF SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, II Chief Deputy, Operations i~` ~ Chief Deputy, Administration PPL ELECTRIC UTILITIES CORPORATION Case Number vs. BAMBI J. NEVILLE 12-6201 CIVIL SHERIFF'S RETURN OF SERVICE 10/12/2012 11:10 AM -DEPUTY COREY STRINE, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN CIVILACTION (CICA) BY HANDING ATRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE RAYMOND SKOLODA, FATHER, WHO ACCEPTED AS "ADULT PERSON IN CHARGE" FOR BAMBI J. NEVILLE AT 728 OLD QUAKER ROAD, APT. 8, LEWISBERRY, PA 17339. REY STRINE, DEPUTY SHERIFF COST: $45.20 October 16, 2012 SO RS, ._. RICHARD P KEU RL BER, SHERIFF ~~C)~~WCr'A~ ~_ - ~ ~ ;°~~dCa'(LV'RiNIA . c~sairr`is~»iUn fcxprr~s, ~~U. ~, 2t71~ ~ Gr v;vc:~is ~, ,3;: r, r4~ibd~:-f~s NOTARY Affirmed and subscribed to before me this 16TH da of OCTOBER 2012 z ~ Co , -ate SY _ :_.__,_